319-325-1171
5438 South Prairie View Drive West Des Moines, IA 50266
Contact
Contact
Complete the form below to contact us for an initial consultation.
Address
5438 South Prairie View Drive
West Des Moines, IA 50266
Phone
319-325-1171
michael@mchristiansconsulting.com
Recent Blog Posts
On Friday, May 10th, Judge Mark Pittman of the United States District Court for the Northern District of Texas granted a preliminary injunction stopping the CFPB's credit card late fee rule from taking effect on May 14th. By way of reminder, the rule would have capped credit card late fees at $8 for large card issuers (those with one million or more open and active credit card accounts). In his opinion, Judge Pittman said that the rule should be stayed pending resolution of CFPB v. Community Financial Services Association of America , a case about whether the CFPB's funding structure is constitutional. That case was argued before the Supreme Court in October 2023, with a decision expected any day. Stay tuned for more details from Michael Christians Consulting, LLC!
The Federal Reserve Board and the Consumer Financial Protection Bureau have issued the revised Regulation CC thresholds, a full 13 months ahead of schedule. By way of reminder, a 2020 rulemaking indexed several Regulation CC thresholds to inflation. Those thresholds are subject to change on July 1st of every fifth year. Effective July 1, 2025, the following changes will take effect: Increase from $225 to $275 the amount of certain check deposits that must be made available on the next business day following the date of deposit (12 CFR 229.10(c)(1)(vii)) Increase the new account exception hold threshold from $5,525 to $6,725. Beginning 7/1/2025, a financial institution may delay the availability of funds in excess of $6,725 deposited to a new account in any one banking day (12 CFR 229.13(a)(1)(ii)) Increase the large deposit exception threshold from $5,525 to $6,725. Beginning 7/1/2025, a financial institution may delay the availability of funds in excess of $6,725 deposited to an existing account in any one banking day (12 CFR 229.13(b)) Change the definition of repeated overdrafts. Beginning 7/1/2025, an account will be considered repeatedly overdrawn if - On 6 or more banking days within the preceding 6 months, the account balance was negative or would have become negative had checks or other charges to the account been paid, or on 2 or more banking days within the preceding 6 months, the account balance was negative or would have become negative in an amount of $6,725 or more (12 CFR 229.13(d)(2)). You can access the final rule here .
Earlier this month, Fannie Mae, Freddie Mac, and FHA announced new requirements for lenders to establish and implement reconsideration of value (ROV) policies and procedures. Fannie Mae and Freddie Mac Lenders must establish policies and procedures that include the steps a borrower can take to appeal an appraisal when they believe the opinion of value is: Unsupported, Deficient due to unacceptable appraisal practices, or Reflects discriminatory appraisal practices. Borrowers must be notified at the time of application and again upon delivery of the appraisal of their right to request an ROV. The new requirements apply to loan applications dated on or after August 8, 2024. Federal Housing Administration Lenders must disclose the following to a borrower at the time of application and again upon delivery of the appraisal: The borrower has the right to initiate an ROV request, The information that he/she will be required to provide in connection with their request, and Expected processing times. The new requirements apply to loans that have an FHA case number assigned on or after September 2, 2024.
Address
5438 South Prairie View Drive
West Des Moines, IA 50266
Phone
319-325-1171
michael@mchristiansconsulting.com
Michael Christians Consulting, LLC
This website has been built to be accessible for all users. If you experience any difficulty in accessing this website, please contact us for assistance.
